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TECHNALYSIS CORPORATION v. COMMISSIONER

Docket No. 3238-91.

67 T.C.M. 2023 (1994)

T.C. Memo. 1994-30

Technalysis Corporation v. Commissioner.

United States Tax Court.

Filed January 26, 1994.

Attorney(s) appearing for the Case

Frank J. Walz and Steven R. Kruger, 3500 IDS Center, Minneapolis, Minn., for the petitioner. Gail K. Gibson, for the respondent.

Memorandum Opinion

GERBER, Judge.

Petitioner has filed a motion for litigation and administrative costs pursuant to Rule 2311 and section 7430. In our opinion of November 4, 1993, we decided that petitioner was not subject to the accumulated earnings tax. Technalysis Corp. v. Commissioner [Dec. 49,378], 101 T.C. ___ (1993). Our findings of fact and opinion are incorporated by this reference.

The issue in the prior...

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